1167t14

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	47
Number of Respondents	41
Total Estimated Burden Hours	3,820
Total Estimated Costs	$544,000
Annualized Capital O&M	$61,500
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$163.17
3. Reporting Requirements										Technical	$130.28
A. Familiarize with regulatory requirements c	1	1	1	41	41	2.05	4.1	$5,945.39		Clerical	$65.71
B. Required activities:
Initial performance tests d	280	1	280	0	0	0	0	$0.00
Reference Method 9 Test e	4	1.2	4.8	0	0	0	0	$0.00
Repeat of performance test f	280	0.2	56	0	0	0	0	$0.00
C. Create information	See 3B
D. Gather Existing Information	See 3B
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0.00
Notification of actual startup	2	1	2	0	0	0	0	$0.00
Notification of any physical or operational change	2	1	2	0	0	0	0	$0.00
Notification of demonstration of continuous monitoring system	2	1	2	0	0	0	0	$0.00
Notification of initial performance test	2	1	2	0	0	0	0	$0.00
Notification that continuous monitoring system (CMS)	2	1	2	0	0	0	0	$0.00
Performance test results	See 3B
Semiannual excess emissions reports g	8	2	16	41	656	32.8	65.6	$95,126.23
Subtotal for Reporting Requirements					802			$101,072
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of CMS operating parameters h	0.25	250	62.5	41	2,562.5	128.13	256.25	$371,586.84
Records of startup, shutdown, malfunction i	1.5	1	1.5	41	61.5	3.08	6.15	$8,918.08
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,018			$380,505		46.6	hr/response
Total Labor Burden and Costs (rounded) i					3,820			$482,000
Total Capital and O&M Cost (rounded) i								$61,500
GRAND TOTAL (rounded) i								$544,000
Assumptions:
a We assume that an average of 41 respondents will be subject to this rule, and that no new sources will become subject to the rule over the three-year period of the ICR.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take 280 hours to complete a performance test.
e It will take respondents 4 hours to conduct a reference Method 9 test.
f We have assumed that 20 percent of new respondents will have to repeat the performance test.
g We have assumed that it will take 8 hour two times per year for each respondent to complete the semiannual report of exceedances.
h We have assumed that it will take 15 minutes, 250 days per year to record CMS operating parameters information.
i We have assumed that it will take 1.5 hours once a year to record information on startup, shutdown, and malfunction.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
Activity:										Labor Rates
Initial performance tests c	38	1	38	0	0	0	0	$0.00		Management	$73.46
Repeat performance test d	38	0.2	7.6	0	0	0	0	$0.00		Technical	$54.51
Report Review:										Clerical	$29.50
Notification of construction/reconstruction e	2	1	2	0	0	0	0	$0.00
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0.00
Notification of physical or operational change f	0.5	1	0.5	0	0	0	0	$0.00
Notification of demonstration of CMS	0.5	1	0.5	0	0	0	0	$0.00
Notification of CMS data to determine compliance	0.5	1	0.5	0	0	0	0	$0.00
Performance test results g	8	1.2	9.6	0	0	0	0	$0.00
Semiannual report h	4	2	8	41	328	16.4	32.8	$20,051.62
TOTAL (rounded) h					377			$20,100
Assumptions:
a We assume that an average of 41 respondents will be subject to this rule, and that no new sources will become subject to the rule over the three-year period of the ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $44.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that it will take 38 hours to observe an initial performance test.
d We have assumed that 20 percent of new respondents will have to repeat the performance test.
e It will take 2 hours to review construction/reconstruction report.
f It will take 0.5 hours to review the physical or operational change review.
g We have assumed that it will take 8 hours to review the performance test results report.
h We have assumed that it will take 4 hour to review each semiannual reports.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent a	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent a	Number of Respondents with O&M	Total O&M, (E X F)			2009 CEPCI	2022 CEPCI
Continuous Opacity Monitor	$23,453	0	$0	$2,345	41	$61,500			521.9	816
a Costs were increased from 2009 $ to 2022 $ using the CEPCI CE Index.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/ reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of any physical or operational changes	0	1	0	0
Notification of demonstration of continuous monitoring system (CMS)	0	1	0	0
Notification of initial performance test	0	1	0	0
Notification that (CMS) will be used to determine compliance	0	1	0	0
Performance test results	0	1	0	0
Semiannual excess emission report	41	2	0	82
			Total	82

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	41	0	0	41
2	0	41	0	0	41
3	0	41	0	0	41
Average	0	41	0	0	41
a New respondents include sources with constructed and reconstructed affected facilities.